FACTS
The spouses Camilo and Conchita Calacala, predecessors-in-interest of the petitioners, owned a registered parcel of land in Pangasinan covered by a Transfer Certificate of Title (TCT). They offered the property as a property bond to secure the provisional release of an accused in a criminal case before the then Court of First Instance. When the accused failed to appear during arraignment, the trial court ordered the bond forfeited in favor of the Government and rendered judgment against the bond for ₱3,500.00. A writ of execution was thereafter issued, resulting in the levy and public auction of the property, where the Republic of the Philippines emerged as the highest bidder. The Sheriff's Certificate of Sale was duly registered and annotated on the title.
Neither the spouses nor their heirs exercised their right of redemption within one (1) year from the registration of the Sheriff's Certificate of Sale. More than eighteen years later, the heirs filed an action for Quieting of Title and Cancellation of Encumbrance, arguing that the Republic never perfected its ownership because it failed to obtain a final deed of sale, execute an affidavit of consolidation of ownership, or secure a writ of possession within ten years. They invoked Article 1142 of the Civil Code, claiming that the Republic's right had prescribed or had been abandoned. The Regional Trial Court dismissed the complaint for failure to state a cause of action, prompting the heirs to elevate the case to the Supreme Court.
The controversy centered on the nature of an action to quiet title under Articles 476 and 477 of the Civil Code. Article 476 allows the removal of a cloud on title only when the adverse claim, though apparently valid, is in fact invalid or unenforceable, while Article 477 requires that the plaintiff possess a legal or equitable title to the property. The petitioners maintained that they remained owners because the Republic allegedly failed to complete the formalities necessary to perfect its title after the execution sale.
ISSUE
Whether the petitioners could validly maintain an action for quieting of title under Articles 476 and 477 of the Civil Code, despite their failure to redeem the property within the one-year redemption period prescribed by Section 33, Rule 39 of the Rules of Court.
Whether the Republic's failure to obtain a final deed of sale, execute an affidavit of consolidation of ownership, or secure a writ of possession within ten years prevented it from acquiring ownership of the property or resulted in the abandonment or prescription of its rights under Article 1142 of the Civil Code.
Whether the complaint sufficiently stated a cause of action considering that the petitioners admitted the validity of the Sheriff's Certificate of Sale and merely questioned the Republic's alleged failure to perfect title after the lapse of the redemption period.
HELD
The Supreme Court denied the petition and affirmed the dismissal of the complaint. It held that the petitioners no longer possessed any legal or equitable title over the property because they failed to redeem it within the one-year redemption period under Section 33, Rule 39 of the Rules of Court. Upon the expiration of the redemption period, the purchaser automatically acquires all the rights, title, interest, and claim of the judgment debtor over the property. Consequently, the petitioners failed to satisfy the first essential requirement of an action to quiet title under Article 477 of the Civil Code.
The Court further ruled that the Republic's ownership became absolute upon the expiration of the redemption period. The subsequent execution of a final deed of sale is merely ministerial and confirmatory, serving only as evidence of ownership already vested by operation of law. Thus, the Republic's failure to execute additional documents or obtain a writ of possession did not impair or delay the transfer of ownership. The Court also rejected the petitioners' reliance on Article 1142 of the Civil Code, reiterating the settled rule that prescription does not run against the State, and that the Government cannot be deemed to have abandoned its rights through the inaction of its officials.
Finally, the Court explained that an action to quiet title under Article 476 of the Civil Code requires that the alleged cloud on title be invalid or ineffective, yet the petitioners themselves admitted the validity of the Sheriff's Certificate of Sale. Since the certificate was valid and the Republic had already acquired ownership after the lapse of the redemption period, there was no cloud to remove. The petitioners therefore had no cause of action, and the complaint for quieting of title was correctly dismissed. The ruling reaffirmed that ownership acquired through an execution sale becomes absolute upon failure to redeem within the period fixed by the Rules of Court, and subsequent formalities do not affect the validity of the purchaser's title
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